KANSAS CITY PLANT SPECIAL EXPOSURE COHORT (SEC 210)ISSUES MATRIX
 

This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their 

technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify 

and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 

No. SEC Issue Post-data capture NIOSH response 

1 

Data Completeness, Legibility, and 

Accuracy – SC&A has not found that 

the completeness and accuracy of the 

recorded bioassay and external 

exposure records, as well as the 

electronic database, has been verified 

for the KCP. This is especially 

important because of the lack of general 

periodic or routine monitoring for KCP 

workers, and also because of the lack of 

legibility of some of the records. This 

issue applies to both bioassays and 

external dose records. 

a) Prior to the KCP visit, during an analysis of 

some of the claimant recorded dose files, SC&A 

found that approximately 50% of the images on 

NOCTS had questionable readability. Therefore, 

SC&A evaluated the situation during the KCP 

visit and found that the original files exist, appear 

to be legible, and are available for DR if needed. 

If the dose reconstructor has any problems 

reading the external or bioassay records, the dose 

reconstructor can contact the KCP and obtain a 

legible copy. b) During the KCP visit, Brent 

Nasca agreed to provide NIOSH with a summary 

of the QA/QC methodology used to audit the 

transfer of the written external and bioassay 

records to the electronic database. NIOSH has 

agreed to provide a copy of that summary to 

SC&A when it becomes available. SC&A will 

then evaluate the process. 

The KCP health physicist (HP) was interviewed and questioned 

by SC&A, Board members and NIOSH regarding this issue at 

the May 2014 KCP site visit. Photocopied images were shown 

to interviewers on the HP’s computer monitor and it was 

demonstrated that legible, accurate records are available. 

Efforts to acquire additional urinalysis records are ongoing. 

NIOSH has reviewed several documents that indicate urinalysis 

was performed beginning in 1951, and that those samples were 

analyzed by LANL. NIOSH has received an example urinalysis 

from an employee’s medical file, and the Team is getting access 

to the LAHDRA holdings to search for additional records. 

There are also some other classified urinalyses listings that 

NIOSH is attempting to capture. 

June 10, 2014 WG: Remaining issue is (b) above; NIOSH will provide a copy of a summary of QA/QC methodology used for transfer of recorded external and 

bioassay records to electronic database when received from Brent Nasca, KCP. 

NIOSH status for January 20, 2015 WG: KCP has not been able to locate documentation of the QA/QC methodology used during the copying of external and 

bioassay records into the electronic database. However, the raw -data records used to create the database remain available to NIOSH for use on DRs and 

coworker modeling. 

ACTION for January 20, 2015 WG: NIOSH committed to provide the WG with a proposed sampling plan for how it intends to validate the electronic 

database with the raw records for both internal and external dose (the latter is also addressed in matrix issue #9, below). Following WG agreement, 

NIOSH would conduct the sampl ing review and provide results. 

7/17/15 – SEC matrix issues 

 

Issue 1 & 9 – NIOSH is working on sampling review, waiting for guidance from the SEC WG coworker plan. 

 

 

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KANSAS CITY PLANT SPECIAL EXPOSURE COHORT (SEC 210) ISSUES MATRIX
 

No. SEC Issue Post-data capture NIOSH response 

2 

Worker Location, Job Category, and 

Coworker Model – Because of the 

varied historic operations at the KCP, 

coupled with the lack of specific worker 

locations and job categories, the 

application of coworker or generalized 

technical basis document derived doses 

could result in incorrect dose 

assignments. This could involve a 

relatively large number of workers 

because in many cases there is a lack of 

(or illegible) bioassay and/or external 

dose records. Therefore, the adequacy 

and completeness of the available data 

used for the coworker model need to be 

addressed, along with their applicability 

to different categories of workers. 

Based on 5/5-8/14 KCP interviews, there were 

conflicting accounts of how freely workers “on the 

plant floor” were able to move from one 

department to another. One interviewee 

recollected moving from job to job, while another 

disagreed, noting that the union restricted such 

movement. Based on past interviews, the 

organizational codes did not necessarily match the 

assigned jobs, which could change over time; 

however, the distinction between operators, 

supervisors, and administrative staff was seen as 

clear. There appears to be a clear delineation and 

access restriction afforded the operating area 

containing the natural and depleted uranium work 

(Depts. 20 and 26). While some scanned records 

on the SRDB are not legible, the original records 

are readable. Further review warranted to 

ascertain whether worker location and job 

category are sufficiently distinguishable for 

coworker modelling. 

This is primarily a TBD issue and NIOSH is planning a revision 

to the TBD. The adequacy and completeness of the available 

data are being addressed in issue 1 above. Interviewees during 

the May 2014 visit indicated that historic radiological operations 

were not that varied (e.g. five separate operations), and that 

personnel movement throughout the radiological facility was 

limited. A better understanding of these classified operations is 

desirable; however, NIOSH has not received any new 

information that thus far appears to conflict with the bounding 

assumptions documented in the SEC00210 Evaluation Report 

(ER). 

June 10, 2014 WG: Remaining issue revolves around application of coworker model to KCP worker categories. Additional bioassay records have been 

requested by NIOSH (as part of medical records) and a future site visit will be scheduled to obtain additional information regarding the adequacy and 

completeness of available data used for the coworker model, along with applicability to various job categories. 

NIOSH status for January 20, 2015 WG: After the writing of the ER, NIOSH became aware of additional bioassay monitoring that was performed by Los 

Alamos for KCP (128346). NIOSH worked with the KCP HP to locate any records of this previously unknown monitoring, and on May 15, 2014, the KCP HP 

uncovered one such record. Learning from this approach, NIOSH compiled a list of employee names from access lists for the Model Shop and Project Royal. 

That list of 550 names was submitted to KCP as part of the data request prior to the October 2014 site visit. As a result, additional bioassay records that were 

filed with medical records were retrieved by NIOSH, and 164 new medical examination and hospital card entries were made to the SRDB. These documents, 

along with additional information regarding the adequacy and completeness of data used for a coworker model andits applicability to various job categories, 

were also retrieved and will be incorporated in the next TBD revision. 

 

 

This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their 

technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify 

and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 
No. SEC Issue Post-data capture NIOSH response 

TBD ISSUE: The WG has combined matrix issues #2 and #3, and agrees that they can be considered TBD issues and moved to the s ite profile matrix 

for later review. 

3 

Chronic vs. Acute – Default chronic 

pattern of intake used in the uranium 

coworker model, apparently being 

applied to most KCP workers, may not 

be applicable to a large number of 

them. SC&A’s review of actual claims 

reveals that workers that have legible 

bioassay records show patterns of 

excretion rates that indicate that the 

coworker model may not be necessarily 

claimant favorable for all workers. 

The operational information obtained during the 

KCP visit indicates that there was the potential for 

acute intakes, i.e., not all operations were 

continuous steady-state production processes. 

Therefore, this issue remains open as an internal 

dose reconstruction issue that NIOSH should 

address. Additionally, the cause of the generally 

higher bioassay reading for 1960–1961 warrants 

further investigation. 

This is primarily a TBD issue and NIOSH is planning a revision 

to the TBD. The ER does not make use of the TBD’s coworker 

model. The TBD 6000 Working Group has also generically 

addressed these chronic vs. acute coworker model issues. 

June 10, 2014 WG: Work group agreed that question regarding chronic versus acute intake patterns does not represent an SEC issue and can be accommodated 

by the TBD 6000 model. The issue of unexplained higher bioassay readings in 1960–1961 will be addressed under matrix issue #18, as part of review of KCP 

incidents. The work group decided to hold matrix issue #3 in abeyance pending further discussion of an internal coworker model for KCP (NIOSH indicates 

above that it does not make use of TBD’s coworker model in the ER) and whether scope of worker category coverage is adequate. 

TBD ISSUE: The WG has combined matrix issues #2 and #3, and agrees that they can be considered TBD issues and moved to the s ite profile matrix 

for later review. 

4 

Super S Uranium – Type S, high-fired 

uranium oxide (UO2) may have been 

handled at KCP and needs to be 

addressed in terms of : 

1) source term and exposure potential; 

and 2) how solubility factors will be 

addressed. [Note: confirmation of 

Type S uranium would not confound 

dose estimation – requires explicit 

acknowledgment in site profile). 

While it was likely that some of the uranium 

handled at KCP was “high fired,” there is no 

clear evidence of insolubility that would preclude 

dose reconstruction with sufficient accuracy. 

Previously addressed by Board for Y-12 and INL; 

no dose reconstruction concerns concluded. 

Recommend closure by the work group. 

NIOSH does not need to address a high-fired uranium oxide 

source-term and exposure potential separately from other KCP 

uranium work because SC&A has previously agreed with 

NIOSH that high-fired uranium oxide is adequately bounded by 

the Type S solubility class (see, White Paper – SC&A Review of 

LBNL Issue #3, dated 9/5/12). 

 

 

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KANSAS CITY PLANT SPECIAL EXPOSURE COHORT (SEC 210) ISSUES MATRIX
 

 

 

This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their 

technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify 

and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 
 

 

Effective Date: 2/02/2015 Draft Page 4 of 33 

KANSAS CITY PLANT SPECIAL EXPOSURE COHORT (SEC 210) ISSUES MATRIX
 

No. SEC Issue Post-data capture NIOSH response 

June 10, 2014 WG: Work group closed this matrix issue. 

5 

Recycled Uranium - SC&A is aware 

of the potential for even DU to include 

recycled uranium once Hanford 

established its recycling program in the 

early 1950s. A cursory search of 

available documents did not reveal 

explicit mention of KCP as a recipient, 

but the potential for trace contaminants 

may exist. Therefore, the potential for 

exposure to radionuclides from recycled 

uranium at the KCP needs to be 

It is the standing position of NIOSH to assume the 

presence of recycled uranium beginning in the 

mid-1950s and to account for it in dose 

reconstruction. TBD 6000, for example, 

addresses recycled uranium in its model 

calculations. NIOSH will assume recycled 

uranium was present at KCP and dose 

reconstruct, accordingly. Recommend closure by 

the work group. 

TBD-6000 Section 2.3 identifies 1952 as the start of RU 

availability. The bounding methodology used during uranium 

work after 1952 includes the exposure contribution from RU 

nuclides. This was implied by reference in the ER to TBD 

6000. [Section 3.1, page 19, discusses how RU is addressed, 

with Table 3.2 providing the assumed nuclide mix]. 

addressed. [Note: confirmation of 

recycled uranium by itself would not 

confound dose estimation – issue is 

explicit acknowledgment as source 

term). 

June 10, 2014 WG: Work group closed this matrix issue. 

6 

DU After 1971 and During and After 

1997 - The nature and extent of work 

with depleted uranium after 1971 and 

again during and after 1997, as well as 

any intakes that may have resulted, 

remain to be adequately established. 

An interview conducted during 5/5-8/14 KCP visit, 

indicates that uranium machining equipment 

remained in place and was not D&D’d until 1975. 

Depleted uranium “ballast” parts were used in 

the KCP telemetry program in the 1980s (and 

possibly beyond) and show up in KCP waste 

inventory; not clear if they were fabricated onsite. 

Further review of “ballast” source term activity 

warranted. 

NIOSH requests that SC&A be more specific as to the DU work 

information missing from the ER after 1971 to the end of the 

evaluated period (12/31/93). NIOSH is not aware of any DU 

work that is not bounded by the methods documented in the ER. 

The period after 1993 did not qualify for evaluation. 

June 10, 2014 WG: NIOSH and SC&A to review more information related to DU ballast parts and other potential source terms identified in KCP 

documentation, e.g., weekly activity reports and SWIMS. [Proposal for ORAUT to send team to KCP to capture these document sets]. 

 

 

This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their 

technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify 

and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 
 

 

Effective Date: 2/02/2015 Draft Page 5 of 33 

KANSAS CITY PLANT SPECIAL EXPOSURE COHORT (SEC 210) ISSUES MATRIX
 

No. SEC Issue Post-data capture NIOSH response 

NIOSH status for January 20, 2015 WG: DU ballasts were not specifically addressed in the ER; therefore, NIOSH was interested to discover if they were 

machined or if they otherwise introduced a new exposure pathway at KCP. NIOSH consulted the literature to gain an understanding of how DU ballasts may 

have been used at KCP, and found the following in NUREG 1717, Section 3.17. Counterweights or ballasts made of DU are used for military ballast and 

counterweight applications. DU counterweights may be used as anti-flutter devices in missile test applications, and have been used in the Trident missile 

program. 

NIOSH collaborated with SC&A and the Board in advance of the October 2014 visit to generate search terms used to locate records related to DU ballast parts 

and other radioactive source-terms. The site-visit team reviewed these records, retrieved activity reports, SWIMS and other documents that provide detailed 

information regarding DU ballasts. However, there were no additional source-terms identified beyond those previously discussed in this Issues Matrix. 

NIOSH reviewed documents that showed ballast parts ordered from ORNL and procedures for the safe handling and assembling of ballast parts (137064, 

128378). NIOSH also reviewed records where DU ballasts appear in KCP’s waste stream. It is noteworthy that when the term “ballast” appears in waste 

records it is with the descriptors “pieces” and or “parts” (e.g. 128402 pp. 45, and 137081), instead of what appears in other known machining processes such as 

the Mg-Th work where the descriptors include “turnings” and “machining waste” (e.g. 134675, pp. 98). 

In light of documents recently reviewed by NIOSH, and classified discussions with Nelson Beard, it is apparent that KCP activities with DU ballasts included 

only the installation of pieces/parts and not on-site machining. Therefore, NIOSH concludes that the ER’s DU bounding methods are also adequate for this 

additional DU work. 

NIOSH and SC&A confirmed to the WG that DU ballast parts were fabricated offsite and would not have presented an exposure potential for workers 

handling them at KCP. No other DU materials unaddressed by the ER were identified during recent onsite data captures. Accordingly, the work 

group closedthis matrix issue. 

 

 

This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their 

technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify 

and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 
 

 

Effective Date: 2/02/2015 Draft Page 6 of 33 

KANSAS CITY PLANT SPECIAL EXPOSURE COHORT (SEC 210) ISSUES MATRIX
 

No. SEC Issue Post-data capture NIOSH response 

7 

Radioactive Waste - Further 

evaluation is warranted in regard to the 

processes and isotopes contributing to 

liquid radioactive waste shipments from 

the Kansas City Plant, the time period 

during which these activities and 

shipments occurred, and the potential 

for unmonitored internal exposures 

from spills, leaks, cleanup, and routine 

handling/storage of contaminated 

drums. 

Several KCP interviews on 5/5-8/14 indicated that 

DU and MgTh turnings were collected in small 

barrels with oil, and staged in a “dump room” for 

disposition. Interviewees did not recall instances 

of leakage or contamination from these drums or 

from the waste disposal process, itself. However, 

LANL documentation indicates instances of 

leakage upon receipt. Further review is 

warranted, with a particular focus on whether 

leakage was limited to uranium. 

NIOSH has reviewed liquid radioactive waste shipment records 

(e.g. SRDB 123835). More records [Solid Waste Information 

Management System (SWIMS)] have also been requested 

(SWIMS example SRDB 123881). NIOSH is not aware of any 

processes or unmonitored internal exposures from spills, leaks, 

cleanup and routine handling/storage of contaminated drums 

that are inadequately bounded with the methodologies described 

in the ER utilizing models developed with approved TIBs and 

TBD 6000. 

June 10, 2014 WG: NIOSH and SC&A to review weekly activity reports, SWIMS and available waste disposition records (KCP and LANL) to ascertain 

radiological waste composition, timeframes and exposure potential. [Proposal for ORAUT to send team to KCP to capture at least first two document sets]. 

 

 

This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their 

technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify 

and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 
 

 

No. SEC Issue Post-data capture NIOSH response 

NIOSH status for January 20, 2015 WG: NIOSH collaborated with SC&A and the Board in advance of the October 2014 visit to generate search terms used 

to locate waste disposition records. The site-visit team reviewed these records, retrieved activity reports, SWIMS and other documents that provide detailed 

information regarding radiological waste composition, timeframes and exposure potential. 

Because of this recently obtained information and further research, NIOSH has developed a better understanding of KCP’s waste types, volumes and disposition 

methods. Examples include, Department 20 D&D waste shipment information (128412, 128419, 137067, 137033, p. 6 and 137081, p. 14, 137045, p. 24), and 

that KCP’s irradiated waste was created by Sandia (134514, p. 14). NIOSH has also reviewed KCP’s Waste Management Implementation Plan (128145, p. 76), 

and found documents that corroborated information obtained during employee interviews. Specifically, maps and details about wastestored in a converted jet 

engine test cell, and at the “Red X lot” (128145, pp. 46, 71, 86, 89, 91). Other documents besides the SWIMS that NIOSH found informative included the 

Radioactive Waste Management Site Plans (128375, 128413, 128414, 128415, and 137045) that provide an annual summary of waste generating activities. For 

example, they describe the amount of waste generated in cubic feet per year, and document a running total of waste stored on-site. Note: The SRDB Ref. IDs 

provided are not an all-inclusive listing of the information now available on this topic. 

Records indicate that KCP’s routine waste generation was minimal and that waste shipments were typically made every two years (137081, p. 16). There were 

many years where a waste shipment was not necessary (137080, p. 5). In fact, there was no waste shipped from June 26, 1974 to 1979 (128375, p. 8 and 137080 

p. 31). There are communications to the DOE that describe the amount of low-level radioactive waste generated at KCP as “essentially insignificant” (134675, 

p. 14). Generation rates at this time were one barrel(134675, p. 96) or 0.283 cubic meters per year (137094, p. 78). NIOSH did observe some years where 

shipments were not routine and larger, explained by the end of KCP’s primary DU machining campaign or the D/20 D&D (e.g. 21 barrels in 1979; 134514, p. 

46). 

As part of this review, NIOSH did not discover any new information that suggests KCP’s waste generating and disposition activities presented exposure 

pathways that were not bounded by the ER’s methodology. 

 

 

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KANSAS CITY PLANT SPECIAL EXPOSURE COHORT (SEC 210) ISSUES MATRIX
 

This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their 

technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify 

and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 
 

 

No. SEC Issue Post-data capture NIOSH response 

January 20, 2015 WG: SC&A indicated that the waste generation characterization provided by NIOSH is only true after the early 1970s; hundreds of drums 

were shipped per year from the late 1950s through early 1970s, particularly during the active DU operational period (1960–1972) (see SRDB 123806, 38160, as 

detailed below). KCP began shipping radwaste to LANL on 3/29/59 (SRDB 38160). In response to WG’s request: Waste composition: DU, “laboratory 

wastes,” including sources, equipment, some Th-232 oxide (SRDB 108241); Timeframes: (SRDB 123806) — based on available manifests located (appear 

incomplete). Exposure potential: Minor contamination found on trucks and on drums of Jan 1962 shipment of 355 drums from KCP to LASL for burial. No 

evidence of KCP worker exposure; no evidence of drum contamination (other than isolated) after 1962 incident, following KCP program response to LANL 

complaints. 

SC&A cited a sampling of shipments for a 10-year period: 

• 1961: 56 drums + 150 “barrels” classified + 295 “containers” of contaminated/radwaste material 

• 1962 (JAN): 137 drums (55 gal) + 218 drums (20 gal)*; (APR): 99 drums (55 gal) + 69 drums (15 gal); (MAY):123 drums (55 gal) + 12 drums (15 gal) 

• 1964: (MAY): 111 + 51 + 55 drums/containers (AUG): 112 drums radwaste + 3 boxes 

• 1965: 111 drums radwaste 

• 1966: 87 + 158 = 245 drums radwaste 

• 1967: 124 drums radwaste 

• 1968: 60 + 127 = 187 drums of radwaste 

• 1969: 2 truckloads of classified/radwaste (17 drums radwaste, classified waste drums) 

• 1970: 2 truckloads of classified/radwaste 

While SC&A disagrees with the NIOSH characterization of waste shipment frequency and volumes as it applies to 1959–early 1970s, we find that the one major 

contamination experienced at LASL appears to have been isolated and spurred KCP to take comprehensive actions to eliminate future contamination. No 

evidence exists that the contamination involved in the one incident led to worker exposure at KCP or LASL. Review of KCP procedures and records for 

radwaste handling have yet to surface any reports of contamination or exposures. 

ACTION: The WG considers this issue open pending additional document searches and worker interviews for information regardin g KCP radwaste 

handling in the 1960s, as well as in the 1980s, with specific attention to whether there existed a radwaste handling group, or whether project personnel 

handled radwaste during these time periods (names of contact personnel were identified at the WG meeting; it was also mentioned by a former worker 

present at the WG meeting that personnel handling waste in the 1980s were disqualified from further work because they were deemed illiterate by 

KCP management). 

 

 

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KANSAS CITY PLANT SPECIAL EXPOSURE COHORT (SEC 210) ISSUES MATRIX
 

This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their 

technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify 

and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 
 

 

No. SEC Issue Post-data capture NIOSH response 

7/17/15 – Issue 7 – 17 – WG came to agreement on both these issues (NIOSH will apply DU coworker model to all unmonitored radwaste 

and D&D workers) 

 

 

Effective Date: 2/02/2015 Draft Page 9 of 33 

KANSAS CITY PLANT SPECIAL EXPOSURE COHORT (SEC 210) ISSUES MATRIX
 

This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their 

technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify 

and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 
 

 

No. SEC Issue Post-data capture NIOSH response 

8 

Metal Tritides – It needs to be 

established the degree to which metal 

tritides were present and how doses 

would be reconstructed to account for 

this potential source of exposure, with 

particular attention to any incidents that 

may have occurred (i.e., only one 

isolated incident?). 

KCP interview of 5/5-8/14 indicates that several types 

of metal tritides were likely handled at KCP in sealed 

components. Historically, there appears to be only 

one instance where a component leaked, resulting in 

tritium contamination involving erbium tritide in 1987, 

but with no evidence of intake. Further review is 

warranted of incident records to confirm no evidence 

of contamination involving tritium and tritide 

containing components. 

Interviews conducted during the May 2014 site visit 

confirmed that the presence of metal tritides at KCP wase 

solely related to contaminated parts being returned without 

adequate decontamination. A second occurrence of metal 

tritide contamination at KCP was described by an 

interviewee, and records of that occurrence will be reviewed 

by NIOSH. 

June 10, 2014 WG: NIOSH and SC&A to review weekly activity reports and other information sources to ascertain the frequency and exposure potential for 

metal tritides at KCP. [Proposal for ORAUT to send team to KCP to capture weekly activity reports]. 

NIOSH status for January 20, 2015 WG: NIOSH collaborated with SC&A and the Board in advance of the October 2014 visit to generate search terms used 

to locate metal tritide records. The site-visit team reviewed these records, retrieved activity reports and other documents that provide detailed information 

regarding frequency and exposure potential for metal tritides. 

NIOSH reviewed reports of weapon’s test assemblies contaminated with low levels of tritides during testing at Pantex and Sandia. There is a timeline of events 

and decisions thatKCP, Pantex and Sandia undertook to ensure these assemblies were decontaminated prior to their return to KCP (123923, p. 65). 

Representatives from each site participated in a demonstration of decontamination techniques in April of 1984 at Pantex (123923, p. 40). KCP established an 

acceptance testing protocol where assemblies were surveyed upon arrival and compared to the shipper’s survey results (e.g., 123862, p. 51). Records of these 

contamination surveys performed by KCP’s consultant health physicist (Benjamin Friesen, PhD) are available (e.g., 123862, pp. 69, 88) 

 

There are reports of four instances where contamination greater than 100 dpm/100 cm2 was detected at KCP during acceptance tests in 1985 and 1988 (123862, 

pp. 30, 97, 143). 

There are three other events described as unusual occurrences where low-levels of contamination were discovered at KCP from 1987 to 1990 (108267; 128248, 

p. 8; 128248, p. 15). 

Because of these three unusual occurrences, the problem was elevated to the attention of the resident authority (senior DOE officials), and a meeting with the 

Albuquerque and Kansas City Area Managers was held in October of 1990 to discuss the problem (123923, p. 51). After this meeting, KCP, Sandia and Pantex 

revised their procedures to prevent future occurrences, and NIOSH has not found evidence of additional tritide contamination finds at KCP after these 

procedural upgrades. 

 

 

Effective Date: 2/02/2015 Draft Page 10 of 33 

KANSAS CITY PLANT SPECIAL EXPOSURE COHORT (SEC 210) ISSUES MATRIX
 

This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their 

technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify 

and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 
 

 

No. SEC Issue Post-data capture NIOSH response 

January 20, 2015 WG: SC&A agreed that the exposure potential at KCP to metal tritide contamination was minimal and isolated, with no evidence of 

worker uptake. Accordingly, the WG closed this issue. 

9 

External Coworker Dose – Legibility, 

accuracy, and completeness of the 

databases (original and electronic) for 

use in developing a coworker external 

dose model has not been verified. 

a) See Issue #1 above concerning QA/QC of 

transferred data. 

b) To date, neither NIOSH nor SC&A has found 

the reason for all the recorded external doses for 

The legibility of monitoring records was verified during the 

May 2014 site visit and NIOSH is satisfied that there are 

methods available to obtain reliable monitoring results. 

Preliminary review indicates the lack of 

legibility and raises questions 

concerning the completeness of the 

external dose records 

1969 being zero. During the KCP visit, Brent 

Nasca agreed to try to determine the cause of the 

records for 1969 being all zero. Brent will contact 

SC&A if he finds anything. 

June 10, 2014 WG: SC&A awaiting communication from Brent Nasca, KCP, regarding status of 1969 records, which may require further follow-up review. 

NIOSH status for January 20, 2015 WG: NIOSH has located a document that independently confirms a zero dose for 1969 (137215, p. 19). KCP to date has 

not been able to locate the Eberline reports from 1969, and has been notified that Eberline’s successor, Thermo Fisher, does not maintain copies of records as far 

back as 1969. 

ACTION for January 20, 2015 WG: The same as for matrix issue #1, with NIOSH to develop and provide a plan on how it will validate the KCP 

electronic record for external doses with original raw records. 

7/17/15 – SEC matrix issues 

 

Issue 1 & 9 – NIOSH is working on sampling review, waiting for guidance from the SEC WG coworker plan. 

 

 

Effective Date: 2/02/2015 Draft Page 11 of 33 

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This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their 

technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify 

and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 
 

 

No. SEC Issue Post-data capture NIOSH response 

10 

Non-penetrating Dose - It appears that 

there are periods (especially 1950– 

1963) where the details of nonpenetrating exposure, dose, and records 

are lacking, making it difficult to 

evaluate non-penetrating doses to 

workers and for developing a coworker 

model. 

SC&A’s research of KCP claims files indicates that 

before 1964, there was a column labeled “RADS” that 

may have been used for recording of the beta dose. 

However, this has not been addressed in the ER or site 

profile documents. The relationship between recorded 

RADS, ROENTGENS, REM, and BETA RAD, as 

recorded at the KCP, needs to be defined, and how 

these quantities will be applied during DR (i.e., how 

will the non-penetrating dose be calculated from the 

recorded data) to determine if appropriate data were 

recorded for DR purposes. 

The ER provides a method to place an upper bound on non -

penetrating doses with sufficient accuracy. NIOSH is aware 

of the dosimetry used from 1950 to 1963, and that KCP 

records show 5,000 entries for non-penetrating doses during 

this time. NIOSH is satisfied that the maximally exposed 

work group and work scenario are represented with the 

available data, and can bound doses to others in the 

evaluated class with their data. 

June 10, 2014 WG: NIOSH to arrange technical call between Matt Smith, ORAUT, and Ron Buchanan, SC&A, regarding the following specific, outstanding 

questions, prior to 1964: [Notes from call and subsequent written statement of issue disposition from NIOSH will be needed for work group review]. 

 

1) Is the “Shallow” dose (such as listed in Column F of the SRDB Ref ID#14707) being derived from the values in the “RADS” column of the original 

data cards? 

2) 

3) 

Which column in the original data cards is the ‘Deep” dose (such as listed in Column D of the SRDB Ref ID#14707) being derived from; the 

“ROENTGENS” or from the “REM” column of the original data cards? 

For DR purposes, is the non- penetrating dose being determined by NP = (RAD-Deep) dose? 

This clarification is needed because the details of non-penetrating dose assignments are not covered in the TBD or ER. 

 

 

Effective Date: 2/02/2015 Draft Page 12 of 33 

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This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their 

technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify 

and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 
 

 

No. SEC Issue Post-data capture NIOSH response 

NIOSH status for January 20, 2015 WG: The technical call between Matt Smith, ORAUT, and Ron Buchanan, SC&A, was conducted on 7/22/14. The notes
 

from that call were sent to the Work Group by Pete Darnell on 7/31/14.
 

The following Action Item was created during the technical call on 7/22/14:
 

NIOSH will provide a summary of their analysis of external dose record terms and what data values are used for DR purposes.
 

The hand-entered film-badge dosimetry data (typically seen prior to 1965) had several columns labeled “RADS,” “ROENT.” and “REM.” After reviewing the
 

derivation of these values and information provided by site personnel, it is determined that the columns can be defined and are used by the Dose Reconstructors
 

as follows:
 

RADS = Open Window (gamma/x-ray + beta) 

ROENT. = Shielded (gamma/x-ray)
 

REM = RADS + ROENT. NOTE: The REM value is a total of the RADS and ROENT. values and is not used by the dose reconstructor.
 

Historically, dose reconstructors have been assigning the RAD value for non-penetrating dose. This is a claimant-favorable approach.
 

NIOSH will also add this analysis of the pre-1965 data to the next revision of the TBD.
 

TBD ISSUE: The WG agreed that the external dose record terms in question can be clarified and included in an update of the T BD. Accordingly, this 

issue is moved to the site profile issues matrix. 

 

 

Effective Date: 2/02/2015 Draft Page 13 of 33 

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This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their 

technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify 

and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 
 

 

No. SEC Issue Post-data capture NIOSH response 

11 

N/P issues – The KCP neutron-tophoton (n/p) ratios as recommended by 

NIOSH are not technically correct and 

require additional investigation in order 

to develop a technically sound approach 

for dose reconstruction. 

NIOSH’s proposed method is not technically correct. 

This is still an issue that NIOSH needs to address. 

Based on OTIB-024, the n/p ratio for alpha reaction in 

uranium and thorium would result in n/p ratios less than 

one; therefore, the ratio stated in the ER is bounding. 

The KCP Site Profile advises the use of an n/p ratio 

approach rather than the use of NTA film with a correction 

factor for neutron dose assignment. The data used to 

recommend the n/p ratio of one are from the post-NTA film 

era, as noted in Section 6.4.3 of the Site Profile. The 

occurrence of positive neutron dose during the post-NTA 

era is very rare, indicating a low potential for neutron 

exposure. It is also noted (from Table 4 in the Site Profile) 

that the same neutron sources were operational during the 

NTA and post-NTA dosimetry eras; therefore, using the 

modern data set to recommend an n/p ratio for the earlier 

era should be valid. 

June 10, 2014 WG: NIOSH agreed that it is not clear what neutron sources were being measured with the NTA film and that OTIB-024 is not an appropriate 

basis for deriving n/p ratios. NIOSH will review these issues and provide the results of its review to the work group. 

 

 

Effective Date: 2/02/2015 Draft Page 14 of 33 

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This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their 

technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify 

and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 
 

 

No. SEC Issue Post-data capture NIOSH response 

NIOSH status for January 20, 2015 WG: The SRDB was searched for information related to neutron radiation at Kansas City Plant. The documents located 

generally corroborated the information provided in the KCP Site Profile, though some neutron sources were found to have arrived at the site earlier than stated in 

the site profile. Neutron generators were in use at the plant in the Test Laboratory. The sources of neutron radiation are described below: 

• A Ra-Be source (20.48 milligrams) was used by Sandia workers while working at KCP January 19–20, 1955. Ra- Be sources typically produce an average 

neutron energy of 3.6 MeV. 

• A Ra-Be source (10 milligrams) was received on July 20, 1962. 

• A Pu-Be source was received on May 11, 1964, from General Atomics. This source was unusually strong at 10 Ci. Pu-Be sources typically produce 

average neutron energy ranging from 4.2–5.0 MeV. 

• A Pu-Be source (73 mCi) was used from 1966–2004 for Boron-10 analysis. 

• There were several neutron generators used (unable to determine the first period of use, but likely used in 1959). The generators identified were a Kaman 

Model A-800, A-850 and a GE U5493 (the GE neutron generator was delivered on July 1, 1984, and is assumed to be in use shortly after this time). The 

neutron energy associated with these generators was 14.7 MeV. It is indicated in 1968 that the maximum weekly exposure is 500 pulses. In 1972, 

measurements of the external surfaces were performed using a Texas Nuclear Neutron Dosimeter System (Model 9140) and provided the following 

measurements: Cabinet surface highest reading – 0.062 mrem/700 pulses and Operator Position highest reading – 0.060 mrem/700 pulses. Later, 

quarterly badge measurements (1990s) taken at 14 and 16 inches from the neutron output indicated the highest average pulse dose of 0.040 mrem/pulse. 

An additional measurement (location of measurement not provided) indicated a dose of 0.79 mrem/pulse at 10 cm from the Kaman Model A-800 neutron 

generator. 

After further evaluation, OTIB-0024, Estimation of Neutron Dose Rates from Alpha-Neutron Reactions in Uranium and Thorium Compounds, is not appropriate 

and should not be used to estimate neutron dose at KCP. 

January 20, 2015 WG: SC&A noted that while the use of only 3 data points is not desirable, statistically, the fact that 32 positive readings were less than these 

3 data points, and there were 2,153 recorded zeros for neutrons, and considering the low potential for exposure to neutrons at the KCP, this is very likely 

(although not statistically strong) a claimant-favorable method. 

ACTION: While SC&A indicated its satisfaction with the methodology proposed, the WG agreed that SC&A should have the opportunity to firsthand 

review the 35 data points from which neutron dose estimation will be based at KCP. NIOSH will provide (or identify location of) the 35 dat a points in 

question to SC&A, with SC&A to report back t o the WG and NIOSH its conclusions, including any remaining questions and comments. 

July 17 2015, the WG closed this issue. 

 

 

Effective Date: 2/02/2015 Draft Page 15 of 33 

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This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their 

technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify 

and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 
 

 

No. SEC Issue Post-data capture NIOSH response 

12 

Fading of NTA - The fading of the 

NTA film as a function of time, 

temperature, and humidity has not been 

addressed, nor were there any 

correction factors provided. Lowerenergy moderated neutrons could have 

gone undetected, and if detected, would 

show even more fading as compared to 

the higher-energy neutrons, such as 

those used for calibrating the NTA film. 

Quarterly exchange of NTA film, such 

as was used at KCP, can result in 

complete loss of countable track and 

yield zero dose recordings for low-level 

and/or low-energy neutron exposures. 

These factors could be indicative of 

why there were very few recorded 

neutron doses, and insufficient data to 

derive a technically sound n/p value. 

During the KCP visit, records of outside vendor 

neutron dosimetry were located. Most of the results 

were recorded as minimum detectable level (M). 

However, with quarterly exchanges, the fading of NTA 

film tracks could significantly contribute to positive 

doses not being recorded. NTA film fading and its 

impact on DR is still an issue that NIOSH needs to 

address. 

The NTA film fading is a common issue and has been 

discussed at multiple sites. A correction factor could be 

developed for KCP; however, it would take significant 

research and may not be justifiable since essentially all the 

neutron doses during the NTA era are "zero." NIOSH will 

perform dose reconstructions using data from the post-NTA 

era and will not use the NTA data. 

June 10, 2014 WG: Similar to its response to matrix issue #11, NIOSH will reevaluate what neutron sources were being measured by NTA film and determine 

whether and what correction factor is appropriate. It is not clear, given this question, whether the “zero” readings are real or not. 

 

 

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This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their 

technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify 

and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 
 

 

No. SEC Issue Post-data capture NIOSH response 

NIOSH status for January 20, 2015 WG: As indicated in the previously submitted response to issues matrix #11, the neutron sources at the KCP appear to be 

confined to Ra-Be/Pu-Be sources and neutron generators. The sources produce an average neutron energy of 3.6 MeV (Ra-Be) and 4.2–5.0 MeV (Pu-Be), 

whereas the neutron generators produced a neutron energy of 14.7 MeV. Typically, NTA film has a neutron energy-response threshold of 0.5 MeV and would 

be able to detect the neutrons emitted by KCP sources/generators. 

In 1993, an appraisal of Radiation Protection was performed at KCP (SRDB 111275) to evaluate their compliance with DOE Order 5480.11, DOE RadCon 

Manual, and applicable occupational radiation protection standards and practices. The appraisal found that users of radiation-generating equipment were 

assigned neutron dosimeters, but there had been no measurable neutron doses in 3 years or on an area dosimeter that had been in a worst-case location for 

3 months. The appraisal indicates that removal of the neutron badges appears to be justified, based on the historical information that less than 0.100 rem would 

be received. 

The sources of neutrons at KCP are essentially the same throughout KCP operations, and annual doses are likely less than 0.100 rem (the dosimetry data 

reviewed from the site confirm that doses greater than 0.100 rem are very infrequent). Since the predominant neutron energy is well above 0.5 MeV, a 

correction factor (which is applied at other sites with lower-energy neutrons) is not needed. The dosimetry records from the site were reviewed and they 

consisted of 13,745 entries, of which 2,188 had neutron monitoring (35 with recorded positive neutron dose; remaining all had zero recorded neutron dose). 

Three dosimetry records were greater than 0.100 rem (0.200 rem in 1966, 0.180 rem in 1988, 0.140 rem in 1970). The 95th percentile dose of the dosimetry 

records with recorded neutron dose (limited set of 35 records) results in a value of 0.154 rem. To account for unmonitored neutron dose that may have been 

received, a bounding assignment of 0.154 rem/year neutron could be assigned for unmonitored workers who worked with neutron sources or neutron-generating 

devices as indicated in the CATI or other available DOL/DOE information. This dose should be assigned using the 2–20 MeV energy range. This approach is 

an overestimate for unmonitored employees and should be assigned as a constant distribution. 

January 20, 2015 WG: SC&A agrees that because of the relatively high energy of the neutron sources and the methods in which they were utilized, the 

potential neutron fields at the KCP would not contain significant doses of low-energy moderated neutrons. Therefore, cut-off response and fading 

would not be a major issue for NTA film as it would be at reactors or heavily moderated medium-energy neutron sources. Accordingly, this issue was 

closed by the WG. 

 

 

Effective Date: 2/02/2015 Draft Page 17 of 33 

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This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their 

technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify 

and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 
 

 

No. SEC Issue Post-data capture NIOSH response 

13 

Mg-Th Alloy operations – 

In the ER NIOSH identified the Mg-Th operations 

period as May 1, 1957 through April 30, 1979, as 

well as a residual period after operations ceased 

and before D&D. For the operational period, 

NIOSH proposes to use engineered air
 

concentration limits coupled with ORAUT-OTIB0070 to bound internal doses. The operations, 

timeframe, data adequacy/completeness, dose 

estimation approach, as well as the 

representativeness of 1970 BZ sampling for null
 

exposure, need to be validated. For the residual
 

period, NIOSH proposes to assume 3E-11 μCi/ml 

lower air limit and deposition, re-suspension, and 

depletion models to assign intakes. Thoron dose
 

assumed to be 5.1 WLM/yr coupled with TBD6000 modeled air concentrations. These
 

assumptions and models need to be evaluated.
 

May 5-8, 2014 interview indicates that Mg-Th 

alloy work commenced as early as 1954. No 

additional air sampling data were identified. 

Further review of operational experience (with 

attention to incident reporting of fires) and 

dose reconstruction method is warranted. 

NIOSH has reviewed the ER and remains satisfied that 

the bounding method is feasible. NIOSH is also 

requesting additional recently located urinalysis records 

to determine if modification of the bounding method is 

required. 

June 10, 2014 WG: NIOSH to review SC&A’s draft white paper, “Review of Internal Exposures to Thorium and Its Progeny at the Kansas City Plant During 

Mg-Th Machining Operations,” when it is issued (8/15/14) and provide response to work group. NIOSH to provide information to verify offsite fabrication of 

Mg-Th received at KCP. NIOSH has requested medical records that may contain thorium bioassay data. 

NIOSH status for January 20, 2015 WG: NIOSH used the available information and created a Response Paper to address this issue titled, Internal Exposures 

to Thorium and its Progeny at the Kansas City Plant during Mg-Th Machining. 

SC&A’s comments at January 20, 2015 WG: Although NIOSH made clear that the Mg-Th machining operations at KCP started August 23, 1961, there is 

contradictory information about the period April 1963–August 1970. 

On page 8 it is written: “After March 1963, there is no other KCP documentation of Mg -Th machining at KCP or elsewhere until August 28, 

1970, when these operation were performed in Department 20 and the Model Shop for the Radec program (SRDB 108264, PDF p. 26). This 1963–1970 

time period with no Mg-Th machining is the same period that DU machining operations were ramping up in Department 20.” 

 

 

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This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their 

technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify 

and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 
 

 

No. SEC Issue Post-data capture NIOSH response 

On page 10 it is written: “Mg-Th machining operations began in Department 20 (AKA Department 22, Heavy Machining Area) August 23, 1961 and 

were only performed in this department until September 21, 1970, when they were moved to the Model Shop .” SC&A believes more information 

would be important to better define Mg-Th machining operations for the period April 1963–August 1970. If Mg-Th machining operations were 

performed in the period April 1963–August 28 1970, in which department did those operations take place? 

On page 8 of NIOSH’s paper it is written: “This 1963–1970 time period with no Mg-Th machining is the same period that DU machining operations 

were ramping up in Department 20.” 

In NIOSH’s response to item 17 of KCP SEC issues matrix for Jan 20 WG meeting it was written: “In 1966, as DU machining work was winding down in 

D/20 (the only orders left were for rings and seal plugs), plans were made to transition to a new project machining polyurethane foam, and to clean 

D/20 and make it into an open area (123895, p. 132). The Facilities group cleaned, and the Industrial Hygiene group surveyed D/20D and D/217- 20D. 

Instructions were provided that stated, “...wet wipe all the walls and ceiling and other areas as the entire area walls and ceiling will be repainted, floors stripped 

and resealed, and equipment requiring decontamination decontaminated. Some of the equipment will go to Department 34C and can be packaged and 

transported to Department 34C. Some of the equipment will have to be disposed...” (123895, p. 133). Areas were surveyed for alpha contamination, and t he 

nature of the contamination was described as follows: “Contamination is commingled with dust and is easily removed, either with soap and water or by 

vacuuming. Contamination levels are generally near the "open area" limit with the 'exception of bus ducts and ventilator-diffuser openings” (123895, pp. 141).” 

While NIOSH and SC&A agree there are no monitoring data after October 1970, SC&A disagrees that there should be reliance on program performance and 

“environmental working conditions” to lend confidence on the use of the 3E-11 μCi/ml limit as bounding for this later period, and that applying any air 

monitoring data from Department 20 to the Model Shop location post-1971 would not be necessarily equivalent. 

Beyond these questions, SC&A agrees with NIOSH’s response to item #3 of its white paper, in that a constant value of 3E-11 μCi/ml, and not the lower value 

of 1.1E-11 μCi/ml (NBS 69 value for Th-232 based on the lung as critical organ), should be applied, as it is more claimant favorable. 

ACTION: SC&A is to complete its review of the NIOSH white paper and provide a formal response to the WG and NIOSH, with joint efforts during 

the anticipated KCP site visit to find more information regarding the 1966–1970 D20 and 1971–1979 Model Shop Mg-Th operations (for the latter with 

attention to engineering process controls and a reported laboratory located under the model shop). The sub-issue of most claimant-favorable Th228/Th-232 proportion (0.19 triple separation or equilibrium) for each cancer organ has been acknowledged as a TBD issue. 

7/17/15 – Issues 13 and 20 – WG came to agreement (held open pending sample DR) 

 

 

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This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their 

technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify 

and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 
 

 

No. SEC Issue Post-data capture NIOSH response 

14 

Post-1993 monitoring – 

Need to validate 1993 cutoff date for 

ER based on NIOSH finding of “no 

apparent, or potentially, inadequatelymonitored exposures,” which was based 

on a review of claims after 10 CFR 835 

was implemented. 

SC&A analyzed NIOSH’s 4/17/2014 response to 

this issue and sampled several case files in view of 

it. To date, SC&A has not located definitive 

information that dose cannot be reconstructed 

beyond 1993; however, SC&A recommends that 

this issue be left open until the other SEC issues 

are resolved. 

During the petition qualification phase, ORAUT performed a 

qualitative assessment that considered job titles and work 

information contained in the CATI. Claim information was 

reviewed for indications that a specific EE’s work duties were 

not represented by the four worker “exposure categories” 

presented in the site profile for assignment of dose to 

unmonitored workers. As stated in petition qualification 

documentation, dose reconstruction methods and assumptions 

would be evaluated through 1993, and if subsequent NIOSH 

evaluation into areas such as decontamination following 

operations indicated potential inadequately monitored exposures 

post-1993, NIOSH would extend the evaluation period into the 

10 CFR pt. 835-era, as appropriate. Since it was determined by 

NIOSH that all doses could be estimated with sufficient 

accuracy through 1993, the evaluation period remained 

unaltered in the final report. NIOSH is aware that DOE 

performed a "Radiological Protection Appraisal" of KCP in 

April 1993, and determined that KCP complied with most of the 

requirements of the DOE RadCon Manual. The few parts they 

were not in complete compliance with were not significant in 

terms of employee monitoring (SRDB 108258). NIOSH is also 

aware that KCP was actively complying with Article 511 of the 

Manual and appropriately removing personnel from the 

monitoring program (SRDB 108258). To illustrate, KCP 

monitored 59 personnel in 1994 using DOELAP accredited 

dosimetry, with only two personnel receiving measureable 

exposures. The two exposures were < 100 mrem TEDE (SRDB 

11987). 

June 10, 2014 WG: SC&A to review NIOSH bases for 1993 cutoff date re: SRDB documents cited in response and in other source documents that provide 

validation of ER statement of “no apparent, or potentially, inadequately monitored exposures” after 1993. 

 

 

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This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their 

technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify 

and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 
 

 

No. SEC Issue Post-data capture NIOSH response 

NIOSH status for January 20, 2015 WG: NIOSH collaborated with SC&A and the Board in advance of the October 2014 visit to generate search terms used 

to locate records related to implementation of 10 CFR 835. The site-visit team reviewed these records and retrieved documents that provide detailed information 

regarding the adequacy of KCP’s monitoring program after 1993. 

NIOSH has reviewed appraisals of the KCP HP program that lead up to the end of the SEC evaluation period. 

A September 1990 appraisal conducted by the DOE’s Albuquerque Operations Office summarized that, “Implementation of the KCP Health Physics Program 

and the Radiation Protection Program meets, and in several areas exceeds, the minimum requirements set forth in the applicable DOE Orders, Regulations and 

Standards. Review of the Radiation Protection Program by the appraisal team revealed a well-designed HP approach to the conduct of radiological operations at 

the KCP” (128208, p. 16). 

In 1990, the DOE Kansas City Area Manager and KCP’s president certified that contamination is controlled on site (128240, p. 5), and certified compliance with 

posting and other requirements of DOE Order 5480.11 and ANSI Standard N2.1 (137035). 

In 1990, KCP certified the following appraisal action item as complete: “Revise and in many cases create a viable Radiation Protection Program that me ets the 

requirements of DOE Order 5480.11; implement this program plant- wide” (137036). 

KCP’s 1990 self-assessment sent to DOE stated, “a health physics action plan has also been prepared which addresses a comprehensive radiation protection 

program. A radiation-protection program manual has been published and internal procedures issued which require departments to come into compliance with 

requirements or write action plans to bring them into compliance within 60 days. Basic radiation training has been given to the entire plant population; all 

radiation sources have been inventoried and sampled for leakage” (137093 p. 24). 

A 1991 Health Physics audit performed by Benjamin Friesen, PhD, found that KCP’s Radiation Protection Program is based on a policy statement signed and 

endorsed by the highest KCP management. Based upon this commitment and all relevant DOE, federal and state regulations, the Radiation Protection Program 

Manual was generated and approved (137086, p. 5). 

KCP received DOELAP accreditation in November 1992 (137219). In December 1992, a letter to the DOE reports that although KCP has 140 employees 

qualified as radiation workers, none of them receive greater than KCP’s local control limit (100 mr/yr), and, in fact, the entire site dose for all 140 rad workers 

combined was 160 mr (128330, p. 13). 

In DOE’s 1995 review (137091) and in the Radiological Control Manual revision (137139) there is no indication of inadequately monitored exposures occurring 

at KCP. 

Interviews with Brent Nasca did not reveal any difficulties with 10 CFR 835 implementation or indications of inadequately monitored exposures after 1993. 

 

 

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This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their 

technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify 

and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 
 

 

No. SEC Issue Post-data capture NIOSH response 

January 20, 2015 WG: During the October 2014 site visit, both NIOSH and SC&A reviewed program documentation that addressed this question. All 

documentation in the years between promulgation of 835 and its implementation at KCP by 1993, indicates a comprehensive approach by KCP and DOE to 

ensure compliance. This included DOELAP accreditation for KCP in November 1992. An interview with Brent Nasca, an HP at KCP during this timeframe, 

indicated no difficulties with 835 implementation or instances of inadequately monitored exposures after 1993. 

Accordingly, the WG decided to close this issue. 

15 

Thorium oxide operations – 

Need to validate that KCP laboratory 

operations involving ThO2 were bench 

scale in nature, and therefore, had 

negligible exposure potential. 

DOE inventory review indicates a standing 

inventory of “non-alloyed” (i.e., non-MgTh) 

thorium at KCP in the 1970s- 1980s. No associated 

KCP program has yet been identified, or attendant 

bioassay program and related bioassays. One 

interviewee from 5/5-8/14 visit recalled a “room 

devoted to thorium;” that it was in “powder 

form.” However, other interviewees to date do not 

acknowledge any programmatic activity involving 

thorium other than MgTh (and formulation of 

laboratory-scale standards; one interviewee noted 

that thorium oxide powder was retained for use as 

an ICAAP standard). Further review is warranted. 

Interviewees were asked about operations involving ThO2 at the 

May 2014 site visit and no large-scale operations were 

identified. The Industrial Hygienist provided additional 

documents during the May 2014 site visit that NIOSH will 

review after they are ADC reviewed. 

June 10, 2014 WG: NIOSH and SC&A review of Bill Frede documents (may need to be re-requested), weekly activity reports (once available), and other 

source documents, to identify any additional information regarding presence of thorium oxide at KCP outside of laboratory standard quantities. 

NIOSH status for January 20, 2015 WG: NIOSH collaborated with SC&A and the Board in advance of the October 2014 visit to generate search terms used 

to locate thorium records. The site-visit team reviewed these records, retrieved activity reports, documents provided by Bill Frede, Brent Nasca and other 

documents that provide detailed information regarding thorium. 

Thorium inventory information was obtained from the Nuclear Material Management and Safeguard System (NMMSS) database (137786). The information 

appears to be incomplete, but it is another data point for NIOSH to consider. For example, KCP is said to possess thorium as alloyed metal in kilogram 

quantities from 1971 to 1976; however, NIOSH has shown that KCP possessed Mg-Th from 1957 to 1979. It may be that NMMSS tracking did not begin until 

1971, and that the only Mg-Th present at KCP after 1976 was as waste awaiting disposal. 

 

 

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This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their 

technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify 

and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 
 

 

No. SEC Issue Post-data capture NIOSH response 

The NMMSS inventory also shows that KCP possessed kilogram quantities of a non-alloyed thorium from 1971 to 1976. The KCP NMMSS custodian was 

asked for information regarding this material; however, being new to the position, she was unable to offer any insight. 

NIOSH has reviewed inventory documents known as AQA Statement of Measurement Methods that cover the time from July 1969 to September 1978. 

Although these inventories show Mg-Th (2% thorium) quantities starting in 1971 through September 1978, there is no mention of non-alloyed thorium forms, 

such as thorium oxide. It is possible that laboratory materials were not included in these reports to DOE, if their total site quantities were maintained at less than 

500 g (123922, p. 3). 

Other documents related to KCP operations with non-alloyed thorium that were recently reviewed by NIOSH include the following. 

There is a 1967 proposal to perform thorium electroplating work in Department 34C (D/34C) (137074, p. 56) 

In 1977, there was work planning associated with electronic assemblies (film circuit resister arrays for measuring the intensity profile of laser beams) with a 

thorium fluoride coated copper substrate, supplied by an outside vendor (137074 pp. 25–28). 

There is a 1979 waste survey showing 22 cu. ft. of a thorium nitrate (10 μCi Th-232) liquid solution in an absorbent (134675, p. 99). There is also a 1979 Solid 

Radioactive Waste Data inventory that shows this material (10 μCi Th-232 or 92 nuclide grams) in absorbent, and a waste shipment record that shows it as one 

gallon of liquid containing 10 μCi Th-232 (137080, p. 58; 134514, pp. 33, 42). 

A 1980 inventory of D/185 (old jet engine test cell) shows 1 gallon of thorium nitrate waste that was received a year earlier (134675, p. 223). This material fit 

into three 55-gallon drums and weighed 274 lbs. 

A 1985 Avoid Verbal Orders (AVO) memo from D/541 to D/187 (Material Conservation and Reclamations) that mentions 24 μCi or 500 grams thorium nitrate 

waste (137045, pp. 5, 95). 

1985 investigation report of a 500 g thorium nitrate shipment with no shipping papers stored for 2 months at Receiving, that was shipped to KCP by mistake 

instead of a facility in Maryland (137074, p. 15). 

A document that shows that the Solutions Analysis section of the Materials Evaluation Lab (D/816) and the Minilab (D/61) store less than 200 g of thorium 

nitrate to “maintain production and critical development support.” Wastes in these labs are to be kept in a designated 5-gallon container and sent to Waste 

Management when full (137074, p. 21). 

In 1986, there are 24 μCi (or 220 g nuclide Th-232) listed in SWIMS, and again as thorium nitrate (500 grams) in unclassified waste barrel #5. This is most 

likely the same material mentioned in the 1985 AVO memo referenced above (137094, pp. 68, 157). 

 

 


 

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This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their 

technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify 

and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 
 

 

No. SEC Issue Post-data capture NIOSH response 

A 1986 procurement document that describes thorium nitrate handling controls, including a 500-g site limit before accountability is required. This document
 

also lists an 810 g shipment to LANL as a “chemical reagent” waste (123922, pp. 2, 15). 

There are 1986 waste handling instructions for thorium nitrate used to make a solution in labs. The lab’s “usage is very small,” and the solution used contains a
 

very small quantity of thorium nitrate (13.8 g used to make a 0.1 normal solution prior to a “fluorine titration” process). Also listed in the document is shipping 

information for 0.11 μCi/g or 13-μCi total of Th-232 (137074, pp. 8–13). 

A 1987 source inventory that shows a 4.77 nCi Th-230 source (128231, p. 6).
 

A 1988 document that describes “research” with solution concentrations of 10 to 100 grams of thorium per liter (1.1 to 11 μCi per liter) and less than 2 liters per
 

day will be generated. This work will be strictly research and development and the anticipated quantities may not exceed 150 lbs/yr (to meet the 10 CFR 40 

exemption). The work will be carried out solely in the laboratory and drain disposal is not allowed for thorium used in R&D (137042).
 

There is a 1989 waste container inventory that has an entry for 113 grams or 0.09 μCi thorium oxide, and another for 100 grams or 10 μCi (137092, pp. 25, 26).
 

A 1989 multi-site (Pinellas, Mound, Inhalation Toxicology Research Institute, and KCP) radioisotope report to DOE, lists 12 Ci Th-230 as the maximum
 

allowable to be stored as solid waste in the Main Manufacturing building. The report is a pre-decisional draft and states that it is important to note this
 

information is preliminary data and is subject to change (13225, pp. 7, 14).
 

A 1989 radioactive material inventory states that 20 g per year of thorium is used in D/61 and D/838 (formerly D/816) to make a 0.1 N thorium nitrate solution 

(128430, p. 42)
 

A 1990 inventory that tracked the following radioactive sources: thorium nitrate for “Solution Analysis” operation; thorium oxide coated tungsten for “XPS”
 

filaments; thorium oxide as a spectrographic standard (128430, p. 18).
 

A 1992 document states that commercially available thorium laboratory reagents are considered non-regulated (128330, p. 9).
 

In December 1992, a letter to the DOE reports an “approximate” amount of 600 g of Th-230 as a compound on a waste inventory (128330, p. 20).
 

A 1993 material safety-data sheet states that the thorium (IV) oxide stored in D/838 was manufactured by Johnson Matthey Cat Chem. (137074 p. 84).
 

At this time, NIOSH is not aware of any other thorium operations at KCP except for weld rods (e.g. 2.5% thorium dioxide; 137074, p. 85). This information, 

combined with the interviews of former employees, leaves NIOSH convinced that KCP’s thorium work can continue to be characterized as small-scale 

laboratory research.
 

 

 

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This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their 

technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify 

and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 
 

 

Effective Date: 2/02/2015 Draft Page 25 of 33 

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No. SEC Issue Post-data capture NIOSH response 

January 20, 2015 WG: SC&A notes that the NMMSS inventory information has not yet been reconciled with the lack of operational information in onsite 

documentation located to date. The current NMMSS custodian at KCP is relatively new to the position and has been unable to offer any insight. SC&A 

deferred to the WG on whether further investigation is warranted; one possibility would be a search of existing Materials Accountability files specific to KCP. 

ACTION: SC&A to complete its review of SRDB records identified by NIOSH from the last data capture , and for both NIOSH and SC&A to continue 

to look for relevant records while conducting onsite searches. 

July 17 2015, the WG closed this issue. 

Natural Uranium, 1950-1958: a) SC&A’s review of the application of TBD-6000 for the Interviewees were asked about access controls and 

16 Application of TBD-6000 

Need to validate proposed application 

exposure to NU during the period of 1950-1955 at KCP 

found the approach adopted in the SEC to be scientifically 

freedom of movement throughout KCP during the May 

2014 site visit. NIOSH remains satisfied that the 

of TBD-6000 methodology to sound and claimant favorable, as long as there were no methodology documented in the ER is bounding. The 

determine if recommended other radiological operations taking place in the Main TBD-6000 Working Group has also generically 

concentrations bound internal doses for Manufacturing Building during this time period. b) addressed the use of the surrogate modeling used in the 

workers that had less exposure SC&A’s review of the use of TBD-6000 methodology for ER. 

potential, or were unmonitored, for unmonitored workers uranium intakes for the 1955-1958 

internal exposures to natural uranium residual time period found the approach adopted in the 

(NU). SEC PER to be scientifically sound and claimant 

favorable, as long as there were no other radiological 

operations taking place in the Main Manufacturing 

Building during this time period. 

SC&A finds that NIOSH’s use of TBD-6000 addresses the 

concerns for uranium exposures. 

June 10, 2014 WG: NIOSH to review SC&A’s draft white paper, Review of Internal Exposures to Uranium at the Kansas City Plant Using TBD-6000 and 

OTIB-0070 as Surrogate Data, when it is issued (7/25/14) and provide response to the WG. NIOSH to provide “mapping” of historic radiological operations 

(beginning with “Troxell” map of 1954), which is ongoing, and, if feasible, provide WG with KCP plant radiological maps for 1950s (i.e., Troxell), 1960s, 

1970s, and 1980s. 

 

 

This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their 

technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify 

and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 
 

 
 

 

No. SEC Issue Post-data capture NIOSH response 

NIOSH status for January 20, 2015 WG: SC&A’s white paper titled, Review of Internal Exposures to Uranium at the Kansas City Plant Using TBD-6000 

and ORAUT-OTIB-0070 as Surrogate Data, provides additional rigor to NIOSH’s KCP SEC evaluation. SC&A independently affirmed NIOSH’s conclusions 

using analysis not performed by NIOSH who was required to complete the ER within 180 days. [NIOSH does not disagree with SC&A’s analysis or 

conclusions; however, minor comments were provided as clarification for SC&A consideration.] 

January 20, 2015 WG: SC&A’s original finding was the need to validate the proposed application of TBD-6000 methodology to determine if the 

recommended concentrations bound internal doses for workers that had less potential, or were unmonitored, for internal exposures to natural uranium. From 

SC&A’s white paper assessment, two conclusions were reached: (1) SC&A’s review of the application of TBD-6000 for the exposure to natural uranium for the 

period 1950–1955 at KCP found the approach adopted in the ER to be scientifically sound and claimant favorable, as long as there were no other radiological 

operations taking place in the Main Manufacturing Building during this time period; and (2) SC&A’s review of the use of TBD-6000 methodology for 

unmonitored worker uranium intakes for the 1955–1958 residual period was found to be similarly valid under the same conditions. The only additional 

clarification would be assurance that no other activities were going on in the Main Manufacturing Building from 1955 to 1958, other than machining uranium 

metal. 

Regarding the additional clarification questions and comments posed by NIOSH regarding the white paper, SC&A concurs with the suggested changes and 

clarifications provided, but will provide these specific responses by separate correspondence (e.g., e-mail). 

SC&A recommended WG closure of this issue, assuming that NIOSH provides the “mapping” of historical radiological operations that was included under this 

matrix issue (which provides added confirmation that the natural uranium operations were the only radiological activity at the time). 

ACTION: NIOSH to forward copies of mapping diagrams of KCP historic radiological operations for review by WG members and SC& A.

July 17 2015, the WG closed this issue. 

D&D activities – Interviews have not identified any significant D&D other Interviewees were asked about the possibility of other 

17 Need to validate scope and monitoring than that in 1984–1986. Other D&D related activities D&D activities by Rockwell International or other 

status of D&D activities; ER assumes involved contaminated equipment, e.g., DU machining. contractors during the May 2014 site visit. NIOSH 

D&D confined to 1984–1986 period No evidence has been found of exposure potential for remains satisfied that the ER’s description of D&D 

and applies assumed air concentration plant workers during D&D. Further review of weekly activities is bounding. 

parameter for general employee activity reports and other sources of operational 

exposure. information is warranted. 

 


 

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This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their 

technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify 

and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 
 

 

No. SEC Issue Post-data capture NIOSH response 

June 10, 2014 WG: NIOSH and SC&A to review weekly activity reports (when available) and other source documents for further evidence of D&D activities. 

(Radiological maps from matrix issue #16, above, helpful to view radiological operational changes over time). 

NIOSH status for January 20, 2015 WG: NIOSH collaborated with SC&A and the Board in advance of the October 2014 site visit to generate search terms 

used to locate D&Drecords. The site-visit team reviewed these records, retrieved activity reports and other documents that provide detailed information 

regarding D&D. NIOSH reviewed the following information that describes decontamination activities other than those described in the ER. 

In 1964, there are surface contamination survey results with grid drawings of the machining area, and instructions to perform decontamination. It was requested, 

“all walls, lighting fixtures, piping and other equipment be wet-washed and the walls painted to remove or fix any loose particulate. The area is to be monitored 

after decontamination” (123895, pp. 11, 32). There are also reports of individual machines decontaminated in1964, 65 (123895, pp. 20, 129, 155, 163). 

In 1966, as DU machining work was winding down in D/20 (the only orders left were for rings and seal plugs), plans were made to transition to a new project 

machining polyurethane foam, and to clean D/20 and make it into an open area (123895, p. 132). The Facilities group cleaned, and the Industrial Hygiene group 

surveyed D/20D and D/217-20D. Instructions were provided that stated, “...wet wipe all the walls and ceiling and other areas as the entire area walls and ceiling 

will be repainted, floors stripped and resealed, and equipment requiring decontamination decontaminated. Some of the equipment will go to Department 34C 

and can be packaged and transported to Department 34C. Some of the equipment will have to be disposed...” (123895, p. 133). Areas were surveyed for alpha 

contamination, and the nature of the contamination was described as follows: “Contamination is commingled with dust and is easily removed, either with soap 

and water or by vacuuming. Contamination levels are generally near the "open area" limit with the exception of bus ducts and ventilator-diffuser openings” 

(123895, p. 141). In 1967, there was a request for improved house keeping in D/34C (123895, pp. 80, 87). 

In 1977, there is a decon procedure for DU and beryllium-contaminated equipment that was performed in the Model Shop (137215, p. 23), and in 1978, 

decontamination and disposal information including surface contamination survey results for equipment and ventilation used with DU operations (137215, p. 3). 

As NIOSH continues to review new information, it is apparent that KCP was cognizant of machining area contamination, and undertook less-formal but 

effective area decontaminations as they transitioned between projects. NIOSH believes that this new information continues to support the general cleanliness of 

the facility and the ER’s bounding methods. 

 

 

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This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their 

technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify 

and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 
 

 

Effective Date: 2/02/2015 Draft Page 28 of 33 

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No. SEC Issue Post-data capture NIOSH response 

January 20, 2015 WG: SC&A noted that the ER only acknowledges the 1984–1986 D&D performed by Rockwell, but does not address what was likely other 

D&D activities over the 60+ year plant history, and whether 1984–1986 dose estimating approach is bounding of these other D&Ds. From the June 10, 2014, 

WG, NIOSH and SC&A were to review weekly activity reports and other source material for further evidence of D&D activities. NIOSH’s most recent matrix 

reflects our joint review that found a number of other instances of D&D activities from the 1960s into the 1970s, involving D&D of operational areas and 

contaminated equipment. There is also evidence in SRDB 132757 of D&D in KCP area D434-20 in the late 1980s. SC&A believes it is not clear that the 

Rockwell D&D of 1984–1986 is bounding of all other D&Ds at KCP; it needs to be confirmed that workers performing D&D in these instances were already in 

a monitoring program. A programmatic basis alone would not be sufficient for bounding purposes. 

ACTION: SC&A to clarify possible path forward on what data or information would inform a NIOSH analysis of whether KCP workers in historic 

D&D activities would have either been already monitored or whose potential exposure would be bound by proposed NIOSH methods at KCP. NIOSH 

would then determine its approach and propose same to the WG. 

7/17/15 – Issue 7 – 17 – WG came to agreement on both these issues (NIOSH will apply DU coworker model to all unmonitored radwaste 

and D&D workers) 

Accidents, Incidents, and Fires in 

Worker’s Record - The status of the 

recording of accidents, incidents, and 

fires in the worker’s records needs to be 

determined. Specifically, NIOSH needs 

to establish whether internal intakes and 

external doses from accidents, 

incidents, and uranium fires were 

included in the records NIOSH has 

available for dose reconstruction or 

whether they need to be obtained and 

accounted for separately from the 

standard recorded intakes and doses. 

This would include the 1987 erbium 

tritide and the 1989 Pm-147 incidents, 

as well as intakes from uranium fires. 

Routine recording of workplace incidents was not 

identified until “weekly activity reports” were found in 

microfilm format during 5/5-8/14 KCP visit – a search for 

all such available reports has been requested. A limited 

sampling of such weeklies for the mid-1960s found 

routine reporting of workplace fires, spills, and accidents. 

The KCP HP was asked about the inclusion of dose 

investigations with monitoring records during the May 

2014 site visit. A dose investigation that includes a 

statement about it being added to an employee’s records 

(SRDB 128233) was shown to the HP and he stated that 

this was a KCP standard practice. Interviewees were 

also asked about their recollection of accidents, incidents 

and fires. NIOSH remains satisfied that the ER’s 

description of D&D activities is bounding. 

The personnel information in documents pertaining to 

the 1987 erbium tritide (SRDB 108267) and the 1989 

Pm-147 (SRDB 6216) incidents has been reviewed 

against NOCTS claimant identifiers, and linked to 

NOCTS claims data as appropriate. The TBD-6000 

Working Group has also generically addressed the 

inclusion of fires and other incidents into exposure 

models. 

18 

 

 

This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their 

technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify 

and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 
 

 

No. SEC Issue Post-data capture NIOSH response 

June 10, 2014 WG: NIOSH and SC&A to review weekly activity reports (when available) to better characterize historic accidents, incidents, and fires with 

radiological exposure implications. 

NIOSH status for January 20, 2015 WG: NIOSH collaborated with SC&A and the Board in advance of the October 2014 site visit to generate search terms 

used to locate records related to accidents, incidents and fires. The site-visit team reviewed these records, retrieved activity reports, and other documents that 

provide detailed information regarding these mishaps. The following reports were reviewed by NIOSH. 

In 1963, there is a detailed evaluation of KCP’s response to a fire in D/22 that resulted from the overheating of an immersion heater. The results of the 

evaluation indicate that, “there were no internal or external radiation exposures or contamination levels of any significance as a result of this incident” (123895, 

pp. 45, 48, 66). 

From 1963 to 1975, there is a folder titled Radiation Incidents containing 153 pages of historical information on radiological incidents. None of the incidents 

were significant in terms of radiation exposures to large numbers of workers. Most apparent doses from the incidents were reasonably small (128479). 

In 1976, there was a shipment of Mg-Th received from a vendor without proper shipping papers (137074, p. 30). 

 

In 1984, High Dosimeter Readings Investigation where a worker was x-raying parts for flaws got a high reading on his dosimeter (128289). 

In 1985, an investigation of a worker’s high TLD reading and his possible exposure while in D/435 performing NDT activities. TLD readings of 3.561 rem 

whole body and 11.153 rem to the skin (111496). 

In 1986, there is a report of a 0.66 rem dose assigned a worker from an x-ray exposure to his dosimeter while working with x-ray beams while using electro 

curtains on cabinets (123843). 

 

 


 

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This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their 

technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify 

and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 
 

 

No. SEC Issue Post-data capture NIOSH response 

In 1989, beta contamination, above limits, was discovered on parts received from Y-12 and identified as DU (137076), and several bottles of krypton-85 gas 

were shipped to KCP by mistake (137073). 

In May 9, 1990, low levels of thallium-204 were found on a source holder case during routine surveys of the waste storage area. This same case was reported to 

be lost on May 29, 1990, and it was determined that it was likely disposed as waste. The evaluation concluded that since “the case was contaminated with less 

that 0.06 microcuries of Thallium 204, the case poses no health hazard. Cross contamination and subsequent internal deposition is unlikely, as the 

contamination had been determined to be firmly affixed to the case” (137118, 137066). 

In a 1990 Exposure Investigation, two workers’ TLDs read unusual shallow doses of 239 and 148 mrem and no deep doses while working as x-ray film readers. 

An investigation was conducted with no resolution as to the dose readings. The dosimeter vender was contacted and TMA/Eberline did indicate that they were 

having trouble distinguishing between low-energy photons and shallow (beta) skin doses. The doses were assigned to the workers (128300). 

A 1991 investigation of an unusual beta dose reports that an Electronic Equipment Technician in D/132/134 performed work on “Neutron Testers” using tritium 

tritides and Ba-133 sources, and received a dose of 60 mrem on his TLD. An investigation ensued and the worker was assigned the dose (128233). 

NIOSH to date has not discovered any events at KCP that rise to the level of a discrete incident as described in 42 CFR 83.13(c)(3)(i), or any events that could 

not be bounded with the ER’s methods. 

January 20, 2015 WG: SC&A noted that a number of records were found during the October 2014 visit that identify accidents, incidents, and fires at KCP. 

While weekly activity reports were only located for a narrow range of years (mid 1960s, early 1970s), a folder entitled “Radiation Incidents” documents 

incidents from 1963–1975. None of these incidents were significant in terms of exposure to large numbers of workers and all could be bounded by NIOSH’s 

DR approach. SC&A deferred to the WG regarding whether closure or additional document searches are warranted. 

ACTION: SC&A and NIOSH to continue searching for additional incident reporting during the upcoming KCP site visit; the WG will review 

NIOSH’s SRDB citations provided. 

July 17 2015, the WG closed this issue. 

 

 

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This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their 

technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify 

and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 
 

 

No. SEC Issue Post-data capture NIOSH response 

19 

Potentially Unmonitored Exposures – 

The ER mentions the concerns of a 

petitioner about potentially 

unmonitored exposures in Section 

7.4.4. However, the response in the ER 

was that NIOSH has determined it has 

sufficient information to document 

potential exposures and bound 

associated doses. Since these are 

specific items, it would be appropriate 

to address the monitoring requirements, 

impacted workers, and available 

records associated with each exposure 

potential to determine dose 

reconstructability for these potential 

exposures. 

Inventory review and interviews indicate no plutonium 

and weapons grade uranium-235 and uranium-233 were 

present at KCP, except in gram quantities in sealed 

sources, or as isolated fugitive contamination in returns. 

External radiation sources, e.g., electron beam welders, 

accelerators, cesium irradiator, and Electro Curtain, 

would have been monitored through film and TLD 

badges. Potential tritium exposure will be addressed as 

a separate issue. Further review of operational records 

and incident reports is warranted. 

The concerns of a petitioner about potentially 

unmonitored exposures were listed in the ER as follows: 

“Many surface and airborne uranium isotopes, 

plutonium, tritium, weapons grade uranium-235, 

uranium-233, neutrons and other ionizing radiation from 

industrial X-ray gauging devices, electron beam welders, 

neutron generators, neutron plutonium-beryllium 

sources, accelerators, cesium irradiator, medical X-ray, 

and Electro Curtain”. 

NIOSH addressed exposures to the evaluated class from 

many of the listed sources throughout the ER. Those 

items not addressed in the ER such as weapons grade 

uranium-235 were omitted because there is no indication 

that they were on site. NIOSH has questioned former 

employees and searched SRDB documents for 

information regarding all of the petitioner’s concerns; 

however, only verified exposures are addressed in the 

ER. 

June 10, 2014 WG: With tritium as the only source term either not discounted or not addressed adequately by NIOSH, the work group closed this matrix issue, 

deferring to matrix issue #20 to address the question of tritium as a potential exposure source at KCP. 

 

 

Effective Date: 2/02/2015 Draft Page 31 of 33 

KANSAS CITY PLANT SPECIAL EXPOSURE COHORT (SEC 210) ISSUES MATRIX
 

This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their 

technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify 

and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 
 

 

No. SEC Issue Post-data capture NIOSH response 

20 

NEW ISSUE: TRITIUM During its May 2014 KCP site visit, SC&A identified the 

availability of KCP site “weekly activities” reports that 

were compiled internally by Bendix and preserved on 

microfilm. In its preliminary review of one such roll, 

weeklies for mid-1964 highlighted the start of a 

heretofore unknown tritium bottling operation where bulk 

quantities of tritium (obtained from Sandia) were 

rebottled into 4 ounce quantities for a yet unknown use. 

This early review also found that these reports contained 

considerable information on accidents and incidents, as 

well as operational status. 

Recommend that the WG open a new issue and further 

review continue. 

NIOSH has been made aware of “Weekly Activity” 

documents obtained during the May 2014 visit that 

indicate KCP performed an operation where tritium 

water was transferred from one-gallon polyethylene 

bottles to 4-ounce bottles. These documents indicate 

that KCP obtained procedures from Sandia to perform 

urinalysis and that KCP was “set -up” to handle tritium 

water (equipment operating satisfactorily and calibrated) 

before they received the first (8) gallon shipment in 

August 1964. This water was received from Sandia and 

certified at 226 μCi/l. There are also indications within 

these reports that KCP ordered (7) additional gallons of 

tritium water in November of 1964. NIOSH also recently 

reviewed a document (SRDB 128438 pdf 3) that seems 

to indicate KCP handled or prepared a tritiated phosphor 

within an exhaust hood, utilizing safe handling 

precautions. This document indicates this work occurred 

prior to October 1968. NIOSH will continue to request 

and review documents that address KCP’s tritium 

operations. 

June 10, 2014 WG: NIOSH and SC&A to review weekly activity reports (when available), and other source documents, to ascertain nature of operation, 

potential worker exposure, and timeframes involved. 

NIOSH status for January 20, 2015 WG: NIOSH collaborated with SC&A and the Board in advance of the October 2014 site visit to generate search terms 

used to locate tritium records. The site-visit team reviewed these records, retrieved activity reports and other documents that provide detailed information 

regarding tritium operations. NIOSH used the available information and created a White Paper titled Tritium at the Kansas City Plant. 

 

 

Effective Date: 2/02/2015 Draft Page 32 of 33 

KANSAS CITY PLANT SPECIAL EXPOSURE COHORT (SEC 210) ISSUES MATRIX
 

This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their 

technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify 

and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 
 

 

No. SEC Issue Post-data capture NIOSH response 

January 20, 2015 WG: SC&A reviewed NIOSH white paper and found that it had more fully characterized historic tritium operations at KCP. However, the 

lack of specific information regarding source terms, operational conditions, and workplace measurements makes it difficult to bound potential worker doses 

without use of broad assumptions, no matter how scientifically founded. It is also not clear which KCP workers were involved in these operations. 

ACTION: NIOSH to update white paper with new information on organic tritium source term; both NIOSH and SC&A to continue loo king for any 

new documentation regarding tritium operations at KCP during the next site visit. 

7/17/15 – Issues 13 and 20 – WG came to agreement (held open pending sample DR) 

 

 

Effective Date: 2/02/2015 Draft Page 33 of 33 

KANSAS CITY PLANT SPECIAL EXPOSURE COHORT (SEC 210) ISSUES MATRIX
 

This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their 

technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify 

and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.